In re the Disciplinary Proceeding Against Sanai, 177 Wash. 2d 743

Fredric Sanai seeks review of a unanimous WSBA Disciplinary Board recommendation disbarring him for multiple RPC violations and frivolous litigation conduct.
The hearing officer found Sanai filed frivolous motions, disobeyed court orders, and pursued similar claims across several jurisdictions to harass and delay.
Sanai’s conduct spanned lis pendens filings, sanctions in state and federal courts, and numerous appeals and petitions concerning his parents’ divorce and related matters.
The Board adopted the hearing officer’s findings, and the Supreme Court reviewed de novo, upholding disbarment with substantial evidence of repeated sanctionable misconduct.
The disciplinary proceedings included challenges to admissibility of evidence, confrontation-clause concerns, subpoenas to judges, and aggravating factors, all ultimately resolved in favor of discipline.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the findings support RPC violations and disbarment?	Sanai argues the findings are flawed or insufficient to prove misconduct.	Board/State argues findings are supported by substantial evidence of frivolous and delaying actions.	Yes; substantial evidence supports RPC violations and disbarment.
Was hearsay admissible and constitutional concerns appropriately addressed?	Sanai challenges hearsay and potential due process issues under confrontation grounds.	Kronenberg precedent permits hearsay in discipline; any error was harmless.	Hearsay admitted under Kronenberg; any error harmless; due process satisfied.
Can unpreserved confrontation-clause claims be raised on appeal?	Sanai asserts confrontation-right issues were violated and should be reviewable.	Claims were not preserved; RAP 2.5(a)(3) bars review absent manifest error.	Unpreserved claims barred; no manifest error shown.
Did the hearing officer have authority to quash subpoenas to judges?	Sanai contends improper quashings and overreach by the hearing officer.	Hearing officer had authority under ELC rules to control subpoenas during the hearing.	No error; hearing officer properly quashed subpoenas.
May aggravating factors be considered without formal charges in disciplinary proceedings?	Sanai claims admission of aggravation violated notice requirements.	Aggravating factors may be considered without additional formal charges.	Permissible; aggravating factors properly considered.

In re Disciplinary Proceeding Against Kronenberg, 155 Wn.2d 184 (2005) (admission of hearsay satisfies due process in discipline cases)
In re Disciplinary Proceeding Against Burtch, 162 Wn.2d 873 (2008) (aggravating factors may be considered without formal charges)
In re Disciplinary Proceeding Against Kuvara, 149 Wn.2d 237 (2003) (upholds standard for appellate review of board decisions)
In re Disciplinary Proceeding Against Poole, 164 Wn.2d 710 (2008) (procedural framework for evaluating disciplinary findings)
State v. Kronich, 160 Wn.2d 893 (2007) (Sixth Amendment confrontation rights in non-criminal context)
In re Ruffalo, 390 U.S. 544 (1968) (due process in disciplinary proceedings and notice requirements)